... but an activity is a trade or business only if a taxpayer. does it continuously and regularly with the honest intent of. making a profit. Commissioner v. Groetzinger, 480. U.S. 23, 35 (1987); see also sec. 183(a), (c). Section 212 allows a taxpayer to deduct expenses incurred in. the production of income generally, but again only if he. ...

... of the statute, the court turned first to the two-prong test of the Supreme Court in Commissioner v. Groetzinger, 480 US 23 (1987):. the primary purpose of the activity must be income or profit, ...

...." The court stated that the Supreme Court's definition of a trade or business in Commissioner v. Groetzinger, requiring a person to engage in an activity for the purpose of income or profit and ...

...The first was from the US Tax Court's decision in Lender Management v. Commissioner (Lender) released on December 15, 2017 which held that a family office, Lender Management, LLC ...(See Commissioner v. Groetzinger (1987)). The IRS will often argue that a family office performs mere clerical and administrative ...

...Groetzinger , 480 U.S. 23, 35, petitioner's nonmember sales must be motivated by an intent to profit. Dispensing with the profit-motive requirement in this case would run counter to the principle of tax ...

... if it is engaged in a "trade or business." The Supreme Court of the United States, in Commissioner v. Groetzinger (480 U.S. 23 (1987)), established a test for when an activity constitutes a "trade ...

... on of a trade or business requires an examination of the. facts and circumstances of each case. Commissioner v. Groetzinger, 480 U.S. 23, 36 (1987). The management of. personal investments, no matter how extensive, is not a. "trade or business." Whipple v. Commissioner, 373 U.S. 193, 200 (1963). . ...

... v . COMMISSIONER OF INTERNAL REVENUE, Respondent, . Nos. 30296-87, 20081-88, 20130-88, 820-96, 24514-91, 30440-91. ...Memo.1989-527, is consistent with the Supreme Court's statement in Commissioner v. Groetzinger, 480 U.S. 23, 35 (1987), that, in order for a taxpayer to be in a trade or business, within the ...

... trade or business requires an examination of the facts and. circumstances of each case. See Commissioner v. Groetzinger, 480 U.S. 23, 36 (1987); see also Woody. v. Commissioner, slip op. at 9-10. When determining. whether a trade or business exists the Court focuses on three. factors: (1) whether the ...

... with continuity and regularity and * * * the taxpayer's. primary purpose for engaging in the activity must be for. income or profit." Commissioner v. Groetzinger,. 480 U.S. 23, 35 (1987). During 2012 the R&E litigation. was JGx5's only claimed "litigation funding". activity. We are not convinced that during 2012 JGx5 was. involved in ...

... the extent that the section 501(c)(7) organization intended. to profit from its unrelated business activities. See sec. 162; Commissioner v. Groetzinger,. 480 U.S. 23, 35 (1987). Thus, petitioner may offset. investment income with losses incurred in sales to nonmembers. only if its nonmember sales were motivated by an intent to. ...

... activities was for income or profit. Thus his activities,. while varied, satisfy the generally recognized definition of. a trade or business. See Commissioner v. Groetzinger, 480 U.S. 23, 35 (1987). Petitioner has not. suggested that he had any deductible business expenses to be. offset against the reported income. . . ...